North Mason School District No. 403Local Government

2024-001 The District did not have adequate internal controls and did not comply with federal Title I eligibility requirements. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: GT-01442 Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards who reside in areas with high concentrations of children from low-income families. During the 2023- 2024 school year, the District spent $753,049 in Title I program funds. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Title I requires participating districts to allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. Furthermore, the District must ensure schools with the highest poverty concentrations receive the most funding per enrolled student. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Description of Condition The District’s internal controls were inadequate for ensuring compliance with eligibility requirements. When the District allocated funding between schools within the same grade span, it only checked that the school with the highest poverty concentration received the most funds. It did not ensure the allocation was adjusted to ensure the per-pupil expenditure (PPE) was higher for the school with the higher poverty concentration, as required. We consider this internal control deficiency to be a material weakness that led to material noncompliance. Cause of Condition Staff responsible for allocating funding misunderstood guidance and believed allocating a higher amount in total to the school with the highest poverty concentration met requirements. Staff did not know about the requirement to also ensure schools with a higher poverty concentration receive an allocation that ensures a higher PPE than schools with a lower poverty concentration. Effect of Condition Because the District allocated Title I funds incorrectly, the amount of services provided at schools with higher percentages of low-income students might have been unfairly limited. The District did not comply with eligibility requirements and did not correctly allocate Title I funds from the highest to lowest poverty elementary school buildings, as federal regulations require. For the two schools within this grade-span, the lower poverty school received $210 more per-pupil than the school with the higher poverty level. Recommendation We recommend the District strengthen internal controls and perform additional research when necessary to ensure staff understand program guidance and confirm it is complete and accurate before ranking and allocating Title I funding to school buildings. District’s Response The district is strengthening its internal controls for monitoring the Per Pupil Expenditure (PPE) to match higher poverty concentration in its schools by the following: 1. Developing and utilizing an Excel Spreadsheet as a “PPE Tool” to allocate funds appropriately a. The PPE Tool will be a shared working document between the Business Office, Human Resources, and Title I Coordinator, b. The PPE Tool will be utilized when applying for the 2025-2026 Consolidated Grant and all future Consolidated Grant applications; and, c. The PPE Tool will be used when completing budgetary reviews at cabinet meetings. These measures will be implemented going forward as internal controls for ensuring compliance with eligibility requirements for Title I funding. Auditor’s Remarks We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 34 CFR, Part 200, Title I – Improving the Academic Achievement of the Disadvantaged, Section 78 – Allocation of funds to school attendance areas and schools

2023-001 The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Assistance Listing Number and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program 10.559 – Summer Food Service Program for Children 10.582 – Fresh Fruit and Vegetable Program Federal Grantor Name: U.S. Department of Agriculture Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The District participates in the Child Nutrition Cluster, which includes the School Breakfast Program, National School Lunch Program, Summer Food Service Program, and Fresh Fruit and Vegetable Program. These programs provide free or reduced-price meals to students from families with low incomes. In the 2022–2023 school year, the District received $1,161,452 in federal funding to administer these programs. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal regulations prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the District enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify that the contractors have not been suspended or debarred or otherwise excluded. The District may verify this by obtaining a written certification from the contractor, adding a clause or condition into the contract that states the contractor is not suspended or debarred or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The District must verify this before entering into the contract, and must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Our audit found the District’s controls were ineffective for ensuring that it verified all parties receiving $25,000 or more in federal funds were not suspended or debarred. The District could not provide documentation showing it obtained a written certification, included a clause in the contract or searched for exclusion records in SAM.gov to verify that one of its three contractors we tested was not suspended or debarred before contracting. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition The District experienced turnover in the position responsible for documenting the verification. District staff was unable to find documentation showing evidence that they performed the suspension and debarment verification for one contractor. Effect of Condition Without adequate internal controls, the District cannot ensure the contractor it paid with federal funds is eligible to participate in federal programs. Any program funds the District used to pay contractors that have been suspended or debarred would be unallowable, and the federal awarding agency could potentially recover them. During the 2022–2023 school year, the District paid the contractor $69,874 of program funds for food service items. We verified the contractor was not suspended or debarred, so we are not questioning these costs. Recommendation We recommend the District strengthen its internal controls to ensure that all contractors it pays $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into contracts with them. District’s Response The District was experiencing high turnover with leadership roles in both its Food Service Department and Business Office when the failure to ensure compliance with federal suspension and debarment requirements occurred with one of its procurement contracts in August 2022. For corrective action the District put in place a requirement that all purchase order requests involving federal funds that amount to (or potentially could amount to) $25,000 or higher must include as an attachment in Skyward Financial Management the contract (when applicable) with verification that the vendor is not suspended and debarred and/or current documentation from Sam.gov verifying the vendor is not suspended or debarred. Any requisition involving federal funds that could amount to or exceed $25,000 that does not also include suspension and debarment verification will not be approved by the finance director and Business Office staff who process purchase order requests (as a control, both the finance director and the accounts payable technician must approve the request). Further, by requiring the suspension and debarment verification in Skyward as an attachment with the purchase order request, Business Office staff (regardless of staff turnover) will be able quickly locate and retrieve the documentation as needed for future audits and other external or internal purposes. Auditor’s Remarks We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations, implementing Executive Orders 12549 and 12689.

North Mason School District No. 403 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, procurement and restricted purpose requirements Assistance Listing Number and Title: 32.009, COVID-19 ? Emergency Connectivity Fund Program Federal Grantor Name: Federal Communications Commission Federal Award/Contract Number: N/A Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $204,685 Background The Emergency Connectivity Fund (ECF) Program provides funding to meet the needs of students and school staff who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning. This is referred to as ?unmet need.? In fiscal year 2022, the District spent $207,536 in ECF Program funds to purchase laptops and broadband services for students and school staff. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Allowable activities and costs ECF Program recipients must only seek reimbursement for the eligible devices and services provided to students and staff with unmet need. Recipients are prohibited from seeking and receiving reimbursement for eligible equipment and services purchased for use solely at the school or held for future use (e.g., warehousing). Equipment The Federal Communications Commission (FCC) requires ECF Program recipients to maintain inventories of the devices and services they have purchased with program funds. The FCC also requires the inventories to include specific elements, such as the type of equipment or service provided, equipment make/model and serial number, name of the students or employees provided the equipment or service, dates they used the equipment or service, and more. Procurement When using ECF Program funds to purchase eligible services and equipment, the FCC requires recipients to comply with all applicable state or local laws by obtaining quotes or following a competitive bidding process, depending on the estimated cost of the purchase. State law and District policy allow for the purchase of goods and services from contracts awarded by another government or group of governments via an interlocal agreement or contract, often referred to as ?piggybacking.? If entering into such an agreement, the District must confirm the awarding entity followed all procurement laws and regulations applicable to the awarding entity when selecting the service provider. Restricted purpose ? unmet need When submitting applications to the FCC, schools only had to provide an estimate of their students? and staff?s unmet need. However, when requesting reimbursement, the District could only request program funds for eligible equipment and services provided to students and school staff with actual unmet need. Restricted purpose ? per-location and per-user limitations The FCC imposed per-location and per-user limitations to maximize the use of limited funds. Under the program, eligible schools could only be reimbursed for one connected device and Wi-Fi hotspot per student or school employee with unmet need, and no more than one fixed broadband connection per location, such as a student?s or employee?s residence. Description of Condition Allowable activities and costs/restricted purpose ? unmet need The District estimated unmet need for eligible equipment and services when it applied for ECF Program funds. However, our audit found the District?s internal controls were ineffective for ensuring it requested reimbursement only for eligible equipment provided to students and school staff with a documented unmet need. Specifically, the District purchased laptops based on its estimate of unmet need, and it requested reimbursement for this purchase totaling $204,685. However, the District did not maintain documentation showing it provided each laptop paid with program funds to a student or employee with unmet need. Equipment Although the District maintains asset inventories, our audit found its internal controls were ineffective for ensuring it included all required elements in the inventories. Specifically, for all laptops purchased with ECF Program funds, the District did not adequately maintain inventories with the required elements, such as the type of equipment provided, equipment make/model and serial number, name of the students or employees provided the equipment, and the dates they used it. Procurement Our audit found the District?s internal controls were ineffective for ensuring it followed state law and its own policy when procuring equipment that it charged to the ECF Program. The District paid one service provider $204,685 for laptops, and it could not demonstrate compliance with procurement requirements, including those for piggybacking. Specifically, the District did not enter into an interlocal agreement with the awarding entity allowing it to piggyback onto its master agreement, nor did it ensure that the original contract it was piggybacking onto was open for use and included the items being purchased. Furthermore, the District did not ensure the awarding entity met its own procurement requirements before using the contract. Restricted purpose ? per-location and per-user limitations Our audit found the District?s internal controls were ineffective for demonstrating it complied with the FCC?s per-location and per-user limitations. Specifically, the District did not maintain documentation showing it monitored or had a tracking process in place to ensure it only provided one device or connection per user and location. We consider these deficiencies in internal controls to be material weaknesses that led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition Allowable activities and costs/restricted purpose ? unmet need The IT Department managed the ECF Program and believed they were operating as the granting agency directed. However, employees were not familiar with all the program?s regulations and federal requirements. Specifically, District staff did not know about the requirement to request reimbursement only for actual unmet need. The District also experienced turnover in the Business Office, which often manages reimbursement requests for its federal programs, and the person responsible was not aware of all the ECF Program?s regulations. Equipment The IT Department did not track computers purchased with program funds. Instead, individual schools were responsible for tracking the computers purchased and provided to students or employees with an unmet need. However, the District did not have procedures in place to ensure schools were properly tracking computers using all the required information. Procurement IT Department staff did not know about the requirements for piggybacking onto a master agreement awarded by another entity. Restricted purpose ? per-location and per-user limitations Staff said they did not know the District needed to maintain documentation showing it only provided one device and/or connection per student and employee. Effect of Condition and Questioned Costs Allowable activities and costs/restricted purpose ? unmet need Because the District did not have documentation supporting whether it provided eligible equipment to students and school staff with actual unmet need, it cannot demonstrate compliance with the program?s requirements. Given the nature of the program and circumstances, it is likely that at least some of the equipment the District charged to the award addressed unmet needs. However, the lack of a documented assessment of students? and staff?s actual unmet need means that most costs are unsupported. Since we do not have a reasonable basis for estimating how much of the District?s expenditures are allowable, we are questioning all unsupported costs. Federal regulations require the State Auditor?s Office to report known questioned costs that are greater than $25,000 for each type of compliance requirement. We question costs when we find the District does not have adequate documentation to support expenditures. Equipment Without maintaining proper asset and service inventory records, as the FCC requires, the District cannot demonstrate compliance with this requirement. Because of missing or inaccurate information, the District cannot effectively track the use of federally funded equipment and services. Procurement The District cannot demonstrate it complied with procurement requirements. Additionally, it cannot be sure all interested service providers had the opportunity to bid and that it obtained the lowest price for the laptop purchases. Restricted purpose ? per-location and per-user limitations Because the District did not maintain documentation, it cannot demonstrate compliance with the FCC?s restrictions. Additionally, we cannot determine whether the District only provided one device or connection per user and location. Recommendation We recommend the District work with the granting agency to determine audit resolution. We further recommend the District establish and follow internal controls to ensure staff fully understand the requirements for ECF awards. Specifically, the District should: ? Request reimbursement only for eligible equipment and services provided to students and staff with unmet need, and maintain documentation demonstrating compliance ? Maintain inventories that include all required elements to track the use of equipment and services paid with ECF Program funds ? Comply with state law and its own policy when procuring goods and services paid with ECF Program funds, and keep documentation supporting the procurement methods it used ? Provide no more than one device per student and employee, and monitor to ensure it distributes equipment in compliance with the ECF Program?s requirements District?s Response Internal Controls The District does not concur with the audit finding or the questioned costs. The District does agree that internal controls and processes could be improved, however this was during the pandemic and we believe the appropriate level of reporting would be a management letter because all costs were allowable and devices were only provided to those with unmet need. While the District does agree that internal controls and processes could have been more carefully followed, these funds were received as an emergency response to prevent learning loss for our students during the crisis caused by the COVID-19 Pandemic when students were not able to attend school in-person. During the District?s urgent need to put computers in students? hands, our schools? computer labs were dismantled and laptops were taken out of classrooms and distributed to students for remote learning. There were not enough laptops available in schools, so the District used Emergency Connectivity Funds (ECF) to purchase 500 additional laptops to serve students? immediate needs. Most of the 500 laptop computers purchased using ECF funds were distributed directly to students based on need identified in a parent survey conducted via telephone and email. Some of the computers purchased using ECF funds replaced the computers that had been removed from computer labs and classrooms out of urgency to put computers in students? hands. School staff did their best to accurately track the issue of the ECF laptops, but due to our lack of a centralized database for this purpose each school used their library check-out systems which assigned new identification numbers to the laptops that were different from the asset tags affixed to the computers by our IT department. Also, in some instances teachers used their own classroom rosters to record who received computers. These deficiencies in tracking were related to the sense of urgency to get computers into students? hands. During the audit the varied ways of tracking and distributing laptops made it difficult to provide timely and clear identification of which students received an ECF-purchased laptop or where the laptops were located in the district. However, in the end, the District was able to provide documentation showing 318 laptops checked out to a student (by name) and 46 laptops placed in library and classroom labs. Therefore, 364 of the 500 computers were being used by students. Also, we showed documentation that 18 of the laptops were returned to the IT Department, meaning they had previously been issued and used by students. The remaining computers were distributed to school buildings for shared use by students during the school day. Unmet Need Based on the guidance below, we have spent all funds for allowable costs, and we believe that those costs were reasonable and necessary and for students with unmet needs. Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. The following guidance from the Federal Communications Commission, titled ?Emergency Connectivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus are eligible for Emergency Connectivity Fund Support.? From the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: ?We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.? And from question 53: ??we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students?with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.? SAO did not apply any reasonable measure to reduce questioned costs but did state they know some of the costs are reasonable, while still choosing to question all costs. That is clearly out of alignment with the FCC guidance. Districts were able to determine whether students had unmet needs, and we initially set out to determine unmet need by surveying families; however, many of our families did not respond to our repeated attempts to communicate with them. We ultimately concluded that all our students had an unmet need for one or more reasons. From the surveys we conducted, and then upon receiving feedback from teachers, we concluded that issuing a district laptop to every student was a necessity. This would address instances where students were sharing a home device with others, their personal device was too old or slow to function properly, when a student owned devices did not have the appropriate security in place to protect students during remote learning. Providing each student with a district laptop also allowed the district access devices to provide technical support for remote learning. Based on these experiences, unmet need was defined broadly. and inventory records were kept, albeit, not perfectly. Piggybacking The District believed it was correctly piggybacking on a master agreement effective Feb 15, 2021 through Feb 15, 2024. The master agreement document was obtained and a quote for 500 laptops at a unit price of $377.30 each was obtained. Regarding master agreement, the District IT Director believed we were following all the necessary steps when he received an email from the Director of Government Contracts at the organization responsible for the master contract, expressing gratitude for considering the contract, stating that leveraging the contract required no additional paperwork, and directing the District how to use the contract. Unfortunately, a different master agreement number was used on the invoice (possibly in error) and the during the audit process the District was unable to obtain supporting documentation of that master agreement. Action Plan Although the District does not concur with the finding or questioned costs, it is taking these findings seriously and has completed an action plan detailing how it will implement stronger controls and ensure compliance in the future. That being said, the standard of documentation required by SAO to satisfy ?unmet? need would have been hard to meet even if the District hadn?t been in the midst of a pandemic. The District has internal controls over asset inventory and provided equipment only to students and staff with unmet needs, and all costs were allowable, reasonable and necessary. We look forward to working with the FCC to resolve this finding and we appreciate the guidance that was provided by the FCC, as noted above. Auditor?s Remarks The State Auditor?s Office is sympathetic to the significant challenges the District faced during the COVID-19 pandemic, and deeply respects its commitment to student learning despite these challenges. SAO knows that in many cases, governments across Washington received significant pandemic-era federal funds without also receiving clear guidance on how to use them. Then, and now, SAO continues to advocate for clear, timely guidance from federal agencies to make sure Washington governments are not put in a difficult position at audit time. However, when auditing federal programs of any kind, governments must provide documentation to substantiate that they met the award requirements. As is our practice and audit standards require, we will review the status of this finding during our next audit. We value our partnership with the District in striving for transparency in public service. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 47 CFR Part 54, Universal Service, Subpart Q, Emergency Connectivity Fund, describes the ECF Program requirements.